Fidelity Advisor Biotechnology Fund (FBTTX) PRE 14A Preliminary proxy

(logo) Fidelity Investments® Fidelity Pricing & Cash Management Services 245 Summer Street Boston, MA 02210–1129 617–563–7000   November 10, 2016

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

RE: Fidelity Advisor Series VII, Fidelity Select Portfolios and Fidelity Covington Trust (the trusts):   Fidelity Advisor Biotechnology Fund Fidelity Advisor Communications Equipment Fund Fidelity Advisor Consumer Discretionary Fund Fidelity Advisor Energy Fund Fidelity Advisor Financial Services Fund Fidelity Advisor Global Real Estate Fund Fidelity Advisor Health Care Fund Fidelity Advisor Industrials Fund Fidelity Advisor Real Estate Fund Fidelity Advisor Semiconductors Fund Fidelity Advisor Technology Fund Fidelity Advisor Utilities Fund   Air Transportations Portfolio Automotive Portfolio Banking Portfolio Biotechnology Portfolio Brokerage and Investment Management Portfolio Chemicals Portfolio Communications Equipment Portfolio Computers Portfolio Construction and Housing Portfolio Consumer Discretionary Portfolio Consumer Finance Portfolio Consumer Staples Portfolio Defense and Aerospace Portfolio

Energy Portfolio

Energy Service Portfolio

Environment and Alternative Energy Portfolio

Financial Services Portfolio

Gold Portfolio

Health Care Portfolio

Health Care Services Portfolio

Industrial Equipment Portfolio

Industrials Portfolio

Insurance Portfolio

IT Services Portfolio

Leisure Portfolio

Materials Portfolio

Medical Equipment and Systems Portfolio

Multimedia Portfolio

Natural Gas Portfolio

Natural Resources Portfolio

Pharmaceuticals Portfolio

Retailing Portfolio

Semiconductors Portfolio

Software and IT Services Portfolio

Technology Portfolio

Telecommunications Portfolio

Transportation Portfolio

Utilities Portfolio

Wireless Portfolio

Fidelity International Real Estate Fund

Fidelity Real Estate Investment Portfolio

Fidelity Telecom and Utilities Fund

Fidelity MSCI Consumer Discretionary Index ETF

Fidelity MSCI Consumer Staples Index ETF

Fidelity MSCI Energy Index ETF

Fidelity MSCI Financials Index ETF

Fidelity MSCI Health Care Index ETF

Fidelity MSCI Industrials Index ETF

Fidelity MSCI Information Technology Index ETF

Fidelity MSCI Materials Index ETF

Fidelity MSCI Telecommunication Services Index ETF

Fidelity MSCI Utilities Index ETF

Fidelity MSCI Real Estate Index ETF

Fidelity Core Dividend ETF

Fidelity Dividend ETF for Rising Rates

Fidelity Low Volatility Factor ETF

Fidelity Momentum Factor ETF

Fidelity Quality Factor ETF

Fidelity Value Factor ETF (the funds)

File Nos. 811-03010, 811-03114, 811-07319

Ladies and Gentlemen:

On behalf of the above referenced funds, transmitted herewith for filing pursuant to Rule 14a–6(a) of Regulation 14A under the Securities Exchange Act of 1934 is a preliminary copy of the Notice, Proxy Statement, and Forms of Proxy to be sent to shareholders in connection with a Special Meeting of Shareholders of the funds to be held on February 24, 2017. Pursuant to Rule 14a–3(c), the required informational copy of each fund’s Annual Report for the fiscal period ended January 31, 2016, February 29, 2016, or July 31, 2016 has been previously furnished to the commission.

We anticipate mailing definitive proxy materials to shareholders on or about December 27, 2016. In order to allow sufficient time to meet this schedule, we would greatly appreciate receiving comments (if any) from the Staff no later than November 21, 2016.

Please contact Jamie Plourde at (817) 474–7037 with any questions or comments relating to this filing.

Sincerely,

/s/ Jamie Plourde

Jamie Plourde

Legal Product Group